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International Tax Blog - New and Interesting International Tax Issues

New IRS Practice Unit - 1120-F Delinquent Returns - Filing Deadline Waiver Process


Yesterday the IRS published a new practice unit titled “Allowance of Deductions and Credits on 1120-F Delinquent Returns.”

Under Code §882(c)(2), an untimely foreign corporation filer is not entitled to deductions and credits.  However, Treas. Reg. §1.882-4(a)(3)(ii) permits the filing deadline to be waived.  This practice unit explains the deadline waiver process.

This new practice unit has been added to our Practice Units By Topic page.

Tags: 882 Foreign Corps with ECI, Other - IRS Practice Units